ML20011E682

Application for Amend to License NPF-42,revising Tech Specs 3.3.2,3.3.3.1 & 3.7.6 Re Control Room Emergency Ventilation Sys Allowed Outage Times Prior to Placing Sys in Emergency Operation Mode

ML20011E682
Person / Time
Site:	Wolf Creek
Issue date:	02/07/1990
From:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20011E683	List: ML20011E682 ML20011E686
References
WM-90-0026, WM-90-26, NUDOCS 9002220184
Download: ML20011E682 (9)

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..=4 CREEK NUCLEAR OPERATING CORPORATION

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Ben D. Wilhers

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February 7, 1990 j

WM 90-0026' U. S. Nuclear Regulatory Commission

-ATTN: Document Control Desk' Mail Station P1-137 Washington, D. C. 20555 i

Subject:

Docket No. 50-482: Revision to Technical Specifications 3.3.2, 3.3.3.1, and 3.7.6 - Control Room Emergency Ventilation System V

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Gentlemen:

The purpose of this letter is to transmit an application for amendment to Facility ~ Operating License No.

NPF-42 for Wolf Creek Generating Station (WCGS),: Unit'No.

1.

This license amendment-request proposes -revising i

L Technical = Specifications'3.3.2, 3.3.3.1, and 3.7.6 Control Room Emergency L

Ventilation System.

The proposed change addresses allowed outage-times prior to ' placing the P

system ~ in its emergency operation mode for the Control Room Emergency Ventilation System and.Its-associated instrumentation.

In addition, the applicability-of Specification 3.0.4 has been revised for consistency.

Wolf-Creek Nuclear Operating-Corporation' requests approval of this: proposed amendment-for use during the upcoming WCGS refueling outage scheduled to-begin on March 8, 1990.

A Safety Evaluation and Significant Hazards Consideration Determination are provided as Attachments I and II, respectively.

The proposed change to the L

Technical Specifications is provided as Attachment III.

l 9002220J84 900207 DR ADOCM 0500049p i

,0 PNU P.O. Box 411/ Burlington. KS 66630 / Phone:(316) 364 8631

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i k4k'90-0076' Page 2 of 2 February 7, 1990 In accordance with 10 CFR~50.91, a copy of this application, with attachments, is being provided to the designated Kansas State official.

This proposed revision to the WCGS Technical Specifications will be-fully implemented'within 30 days of formal Nuclear Regulatory Commission approval.

If you have any questions concerning this matter, please contact' me or H. K. Chernoff of my staff.

Very truly yours.

L; AJ Bart D. Withers President and Chief Executive Officer

.BDW/aem Attachmentsi I - Safety Evaluation II - Addressing The Standards In 10 CFR 50.92 III - Proposed Technical Specification Changes cci G. W. Allen (KDHE), w/a B. L. Bartlett (NRC), w/a E. J. Holler (NRC), w/a R. D. Martin (NRC), w/a D. V. Pickett (NRC), w/a 9

r STATE OF KAR$AS

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) SS COUNTY OF COFFEY

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i Bart D. Withers, of lawful age, being first duly sworn upon oath says that he is President and Chief Executive Officer of Wolf Creek Huclear Operating Corporation that he has read the foregoing document and knows the content thereof that he has executed that same for and on behalf of said Corporation with full power and authority to do son and that the facts therein -stated are true and correct to the best of his knowledge, information and belief.

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Bart D. Withers President and Chief Executivo Officer SUBSCRIBED and sworn to before me this 7 day of 4 1990.

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', 'Att:chment I to WM 90-0026

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ATTACIBEENT I SAFETY EVALUATION L

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Att:chment I to WM 90-0026 1

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Safety Evaluation PrODoS9d CbARR9 j

The purpose of the proposed technical specification changes is to revise the ACTION statements of Specifications 3.3.2, 3.3.3.1 and 3.7.6 concerning the 1

Control Room Emergency Ventilation System and its associated actuation 1

-instrumentation such that an exception to Specification 3.0.4 is allowed for ACTION statements which permit continued plant operation for an unlimited period of time and to establish a consistent allowed outage time prior to placing the system in its emergency mode of operation.

As currently written entry into the actions described above would restrict operational chenges in MODES, because of the requirements of Specification 3.0.4.

This would result in an unnecessary delay in changing an operational MODE since as currently written these ACTIONS allow continued operation for an unlimited tin 4e period.

In addition the change establishes 7 days as the l

consistent allowed outage time to be applied prior to placing the system in its emergency operational mode.

Backaround The Control Room Emergency Ventilation System (CREVS) provides the control L

room with a conditioned atmosphere following various Design Basis Accidents (DBAs) such as Loss.of Coolant Accident (LOCA),

fuel handing accident, rod

-ejection, main steamline break and steam generator tube rupture.

This system ensures that the instrumentation and equipment located in the control l:

room will be maintained within their design temperatures and that the l

control room will remain habitable.

The Control Room Emergency Ventilation System consists of two ceparate and redundant 1 trains which recirculate the control room air.

The system-initiates filtered ventilation of the control room following receipt of an actuation signal. The CREVS design basis is established by the consequences of the limiting DBA which is a LOCA in MODE 1, 2,

3 and 4 and a fuel handling accident in MODE 5 and_6..

The LOCA analysis assumes that only one train of the CREVS is functional due to a single failure which disables the other train. The design basis is also established by the potential chlorine gas sources which would have the potential for incapacitating personnel in the control room if mitigating actions were not taken.

Evaluation Currently inconsistencies exists between the requirements of Technical Specifications (T.S.)

3.3.2,

" Engineered Safety Features Actuation System Instrumentation",

3.3.3.1,

" Radiation Monitoring for Plant Operations",

3.3.3.7,

" Chlorine Detection System",

and 3.7.6,

" Control Room Emergency Ventilation System." The proposed change would add the stipulation to T.S.

3.3.2 (Table 3.3-3, ACTION 26) and 3.7.6 (MODE 5 and 6, ACTION a.) that the provisions of Specification 3.0.4 are not applicable.

This flexibility exists in T.S.

3.3.3.1 and 3.3.3.7.

In addition the proposed change would establish 7 days as the consistent allowed outage time prior to placing the CREVS in its emergency operation mode for the condition where one CREVS train or one train of CREVS actuation instrumentation is inoperable.

This amount of time is currently allowed by T. S. 3.3.3.7 and 3.7.6

^At't0chmentLI to WM 90-0026 f*

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The proposed change would allow WCGS to make operational MODE changes in MODES 5 and 6 while operating in accordance with existing ACTIONS, which allow continued operation for an unlimited time period.

This change is consistent with the-guidance provided in Generic Letter 87-09, which

- acknowledges that it is overly conservative to restrict operational MODE changes under conditions which provide an acceptable. level of safety for unlimited continued operation.

This-proposed change will thereby eliminate-a situation that could result in'a delay in plant startup.

Establishing a consistent allowed outage time for conditions where either one' train of the CREVS or one train of the CREVS actuation instrumentation.

is inoperable provides a uniform approach to the loss of one functional c

CREVS train including its actuation instrumentation.

The allowed outage time prior to placing CREVS is in.its emergency operations mode is based on the' existing allowed outage time for the CREVS and its chlorine-detection

'l actuation instrumentation.

Based on engineering judgement considering that the remaining train can provide all the required capabilities and that 7 E

days allows an adequate amount of time to accomplish most repairs, the existing time of 7 day in T.

S.

3.3.3.7 and 3.7.6 has been determined appropriate for incorporation into T. S. 3.3.2 (Table 3.3-3, ACTION 26) and 3.3.3.1 (TABLE 3.3-6, ACTION 27).

This change also serves to clarify; the requirements for the CREVS and its actuation instrumentation by eliminating an existing discrepancy between the various specifications.

l-Since-the proposed changes do not alter the function or capabilities of i

existing : plant equipment, these changes do not involve an increase in the

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probability or consequences of any accident previously evaluated.

These 1

changes. modify the WCGS technical specification to allow allow consistent 1

= application-of allowed outage times prior to placing the CREVS in its j

emergency operation mode and eliminate overly conservative restrictions on l

operational MODE changes, however no new or different kind of accident is created.- Since no changes are proposed to any system operational acceptance l '

criteria, no change in the: margin of safety exists.

Therefore, the l

requested -changes do not alter the safety deeign basis of WCGS or adversely affect the health and safety of the public.

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Attachment II to N 90-0026 Page 1=._cf 3-g, L

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s ATTACIDEllT II ADMRASING STAlm&RDS Ilt 10 CFR 50.92 i

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Att:chment II to WM 90-0026 l

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Addressina the Standards of 10 CFR 50.92 The-proposed changes would revise the ACTION statements of Specifications 3.3.2, 3.3.3.1 and 3.7.6 concerning the Control Room Emergency Ventilation System (CREVS) and its associated actuation instrumentation such that an exception to Specification 3.0.4 is allowed for ACTION statements which permit continued plant operation for an unlimited period of time and to establish a consistent allowed outage time prior to placing the CREVS in its emergency operation mode.

The following sections discuss the proposed change under the three standards of 10 CFR 50.92:

Standard I - Involves a

Significant Increase in the Probability. or Consequences of an Accident Previously Evaluated, t

The proposed changes do not effect equipment involved in the initiation of previously evaluated accidents.

The probability of such accidents is therefore not increased.

The Control Room Emergency Ventilation System (CREVS) and its actuation instrumentation functions to mitigate the consequences of accidents bv. maintaining control room habitability.

The proposed change does not alter the design or method of operation of the l

Control Room Emergency Ventilation System or its actuation instrumentation.

The revised ACTIONS would allow WCGS to make operational changes while operating in accordance with existing ACTIONS which allow continued l

operation for an unlimited period of time provided the system has been placed in its Emergency mode of operation.

Operational HODE changes within the bounds of the ACTION would not degrade the capability of the Control Room' Emergency Ventilation System to mitigate an accident, therefore, the consequences of previously analyzed accidents are not increased by the proposed _ changes.

The. proposed consistent allowed outage time of 7 days prior to placing the l

CREVS in its emergency operations mode is based on-engineering judgement, considering that the remaining train can provide all the required capabilities and that 7 days allows an adequate amount of time to complete most -repairs.

Additionally it is judged that the probability of a Design Basis Accident occurring during this time period is acceptably small.

Standard II - Create the Possibility of a New or Different Kind of Accident Frosa any Pretriously Evaluated.

The proposed changes to not introduce any new equipment into WCGS or require any existing equipment to operate in a different manner from which it was designed to function.

Since the proposed changes do not introduce any new or revised failure modes, a new or different kind of accident could not occur.

Standard III - Involve a Significant Reduction in the Margin of Safety This proposed changes do not affect the margin of safety for any design basis accident.

The changes only alter restrictions on making operational MODE changes and the period of time one CREVS actuation instrumentation train may be inoperable prior to placing the system in its emergency operation mode, no acceptance criteria for any Design basis accident are changed

P' Att chment II t2 WM 90-0026

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Based on the above discussions.

it has been determined that-the requested Technical Specification revisions do not involve a significant. increase in

the probability or consequences of an accident or other adverse condition over previous evaluations

or create the possibility of a new or different kind of accident' over previous evaluations or involve a' significant-reduction in a margin of safety. Therefore, the requested changes do not involve a'significant hazards consideration 1

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